Investment firms must define and implement remuneration policies and practices under internal procedures that take into account the interests of all clients to ensure fair treatment and that clients’ interests are not impaired in the short, medium or long term. Remuneration policies and practices must be designed so as not to create conflicts of interest or incentives that may lead relevant persons to favour their own interests or the firm’s interests to the potential detriment of any client, and must apply to all relevant persons whose remuneration or incentives may affect investment or ancillary services or the firm’s corporate behaviour, regardless of client type.

The management body must approve the remuneration policy after taking advice from the compliance function, while senior management is responsible for day-to-day implementation and monitoring of compliance risks related to the policy. Remuneration and similar incentives must not be solely or predominantly based on quantitative commercial criteria and must fully take into account qualitative criteria reflecting regulatory compliance, fair treatment of clients and quality of services; a balance between fixed and variable components must be maintained so the structure does not favour the firm or its relevant persons against clients.